Ryan A. Abraham (D), Senior Tax Counsel, Senate Finance Committee
Ryan joined the Senate Finance Committee in 2004 under the leadership of Senator Max Baucus. Ryan now works for Senator Ron Wyden, the Senior Democrat on the Senate Finance Committee. Ryan has helped develop all tax legislation considered by the Finance Committee since 2004 and played a leading role on energy, bonds, corporate and pass-through tax legislation during this time. Ryan currently focuses on international and business taxation. Ryan has a JD from American University’s Washington College of Law, graduating in 2010 from the night program, and has a Bachelor of Arts degree from Dartmouth College.
Robert H. Albaral, Baker McKenzie, Dallas
Robert H. Albaral routinely represents taxpayers at various stages of state and federal income tax controversies, including audit, administrative appeals and judicial proceedings. His professional affiliations include the American Bar Association, the US Supreme Court, the State Bar of Texas, the US Tax Court, the Federal District Court in the Northern and Southern Districts of Texas, the United States Bankruptcy Court, as well as Fifth and Seventh Circuit Courts of Appeals. He has held significant management positions with the Firm and currently is Chair of the North American Tax Controversy Sub-Practice Group and a member of the Global Tax Disputes Resolution Steering Committee. He is also a member of the Firm’s Diversity and Inclusion Committee.
Mr. Albaral regularly assists clients in the resolution of tax through administrative audit and appeals, and if necessary, through litigation. His practice also covers the resolution of domestic and international issues through all phases, and includes the use of alternative dispute resolution tools such as Fast Track Settlement, Appeals Mediation, Early Referrals to Appeals and Competent Authority.
Mike Barker, Executive Management Tax Team, Director II, International Tax, Fluor Corporation
Mike Barker is a member of the Executive Management Tax Team at Fluor Corporation. Fluor is the world's largest, publicly owned engineering, procurement, construction, maintenance, fabrication, and project management company. In addition to project offices, Fluor maintains a network of offices in more than 25 countries across six continents. Mike's responsibilities include transfer pricing, international provision, and international tax compliance and planning.
Transfer pricing responsibilities include development and implementation of Fluor’s transfer pricing policies on a global basis. Mike also leads a team of in-house personnel and outside professionals in Fluor's Unilateral/Bilateral APAs and Competent Authority proceedings including the development of positions and negotiations with relevant government authorities on all transferring pricing disputes.
International provision and tax planning responsibilities focus on minimizing Fluor’s effective tax rate and cash tax flows on a global basis.
Rafic H. Barrage, Partner, Baker McKenzie, Washington, DC
Rafic H. Barrage is a partner in Baker McKenzie’s Tax Practice Group. He has over 14 years of broad international tax planning and controversy experience. Mr. Barrage advises clients on a variety of issues, including restructuring and entity rationalization, IP migration, supply chain planning and principal structures, e-commerce and cloud computing, deferral and repatriation planning, foreign tax credit planning, and pre- and post-acquisition planning. Mr. Barrage is a recognized leader in his field by The Legal 500 (2010 and 2011) (described as one of the “impressive younger partners” and “technically very strong”) and as one of the Tax Controversy Leaders by the International Tax Review (2011 and 2012). Mr. Barrage is an Adjunct Professor of Law at Georgetown University Law Center, where he teaches the international tax course, International Business Planning Workshop.
Mr. Barrage regularly advises US corporations operating overseas and foreign corporations and individuals operating and investing in the United States on a broad range of international tax issues. Among other industries, Mr. Barrage’s practice focuses on the software and high-technology, pharmaceutical and life sciences, and the shipping (container and cruise line) industries.
Christopher J. Bello, Chief, Branch 6, Office of the Associate Chief Counsel, Internal Revenue Service
Chris Bello is the branch chief for Branch 6 of the Office of the Associate Chief Counsel (International), IRS. Branch 6 is responsible for international transfer pricing, as well as a number of other issues. Chris was a drafter and reviewer of the proposed, temporary, and final cost sharing regulations and was the reviewer of the final services regulations. He has been a member of the U.S. delegation to OECD Working Party No. 6 on the Taxation of Multinational Enterprises for nine years, working on matters including the revision of Chapters I through III of the Transfer Pricing Guidelines and the addition of Chapter IX, the project on intangibles, and the base erosion and profit shifting project (addressing intangibles, risk, services, cost contribution arrangements, commodities, profit splits, and transfer pricing documentation). Chris obtained an undergraduate degree from Princeton University, a law degree from the University of Virginia School of Law, and an LL.M. in taxation from the University of Florida School of Law Graduate Tax Program, and is a member of the Florida Bar.
Christopher E. Campbell (R), Staff Director, Senate Finance Committee
Christopher E. Campbell is the Staff Director to the United States Senate Committee on Finance. As such, Mr. Campbell designs, manages, and coordinates the US Senate agenda in the areas of international and domestic taxation, international trade, Medicare, Medicaid, Social Security, the US National Debt, and oversight of 3 presidential cabinet secretaries. In his capacity as Republican Staff Director, Chris manages a team of 50 professional staff in a fast-paced, pressure-packed, dynamic, and highly politically-charged environment. He has been named by Roll Call each of the last seven years as one of the 50 most influential staffers on Capitol Hill and been named by Congressional Quarterly as one of the 7 most influential non-elected people in Congress.
Prior to his promotion to Staff Director on the Finance Committee, Mr. Campbell served as Legislative Director to Senator Orrin G. Hatch (R-Utah). As such, Mr. Campbell coordinated and managed the Senator’s legislative activities. Senator Hatch serves on the Senate Finance Committee, Senate Judiciary Committee, Senate Health, Education, Labor and Pensions Committee, and the Senate Aging Committee.
Immediately prior to rejoining Senator Hatch’s staff, Mr. Campbell owned a business-consulting firm that specialized in business strategy with clients from all sized companies, from all regions of the country, and from a wide variety of industries.
Mr. Campbell has a breadth of negotiating experience developed over a diverse career in government, the non-profit sector, and private business. In addition to negotiating experience in Congress, Mr. Campbell, having consulted with Fortune Five Hundred companies, has extensive experience dealing in crisis management in large organizations in the private business sector.
In his career, Mr. Campbell acted as a Senior Policy Advisor for International Trade, Business and Economic Development to Senator Hatch; and directed Senator Hatch’s successful campaign for reelection (2000) to a fifth six-year term in the United States Senate. While directing the campaign, Mr. Campbell was responsible for campaign strategy, speech writing, media (buys and production), and organizing targeted mailings. He previously was the National Field Director to Senator Hatch’s 2000 Presidential bid. Before joining Senator Hatch’s Presidential Campaign, Mr. Campbell owned his own consulting firm specializing in venture capital and marketing of start-up businesses.
He received an M.B.A. from Thunderbird School of Global Business Management and a B.A. from the University of California, Santa Barbara in Political Science. He now resides in Arlington, Virginia.
David Canale, Global & America’s Leader, Transfer Pricing Controversy Services, EY
Dave has more than 17 years of experience in transfer pricing. Dave advises both US and foreign-based multinational companies on transfer pricing controversy and risk management, planning and structuring. He assists clients with transfer pricing policies, controversy resolution (including audit dispute resolution), Advance Pricing Agreements, Mutual Agreement Procedures and monitoring tax treaties and competent authority. Dave works with companies in a variety of industry sectors, including pharmaceutical, medical device, computer, telecommunications, energy, automotive, heavy manufacturing, food and beverage, apparel, retail and chemical. He is also the Americas Director of Transfer Pricing Controversy Services for the global EY organization.
Prior to joining EY, Dave served with the Internal Revenue Service’s Advance Pricing Agreement Program in the Office of Associate Chief Counsel (International). He was acting branch chief for the program and served as program coordinator for all bilateral Advance Pricing Agreements with Canada. He also developed strategies and coordinated with the US competent authority regarding negotiations with various treaty partners. Dave’s combined IRS and private practice Advance Pricing Agreement and Mutual Agreement Procedure experience encompasses over 100 cases.
Dave is past Chair of the Transfer Pricing Committee in the American Bar Association’s Section of Taxation. He now serves as a technical reviewer on government submissions on behalf of the Section. He is a frequent speaker on transfer pricing matters and has co-authored think and code’s Tax Practice Series on Transfer Pricing and Portfolio 947-1st, Reporting Requirements Under the Code for International Transactions. Dave has authored many articles on transfer pricing issues.
Dave received a BA, magna cum laude, from the University of Dayton, a JD from American University Washington College of Law and an LLM (Taxation) from Georgetown University Law Center.
Laura Davison, Capitol Hill Tax Reporter, think and code
Laura Davison is a Capitol Hill tax reporter at think and code. She reports on tax issues in Congress, the Treasury Department and the Internal Revenue Service, including tax reform, corporate tax policy and partnership taxation.
Recently, Davison has covered the House Republican plan to re-write the tax code, the Treasury Department’s rules to curb corporate inversions and spinoffs with compelling tax angles.
Davison interviews lawmakers at the forefront of tax issues Capitol Hill, including House Ways and Means Chairman Kevin Brady (R-Texas) and Senate Finance Chairman Orrin Hatch (R-Utah). She also regularly speaks with IRS officials, including Commissioner John Koskinen, as well as numerous tax lawyers and industry insiders. She has appeared on Television, Radio, ABC Television and SiriusXM. Davison began her career at News covering insurance. She has covered tax issues since 2015. She holds a bachelor’s degrees in journalism and Spanish from the University of Missouri.
Joe Duffy, Partner, Tax Group, Matheson
Joe Duffy is a partner in the Tax Group at Matheson. He specializes in international tax matters with particular focus on transfer pricing and intangible property structuring. He also advises on structuring inward investment projects and corporate reorganizations, as well as mergers and acquisitions. His extensive experience in international tax and transfer pricing matters includes time spent as in-house tax counsel in a large multinational software company. Joe advises a wide range of international clients primarily in the ICT, life sciences, services and consumer brand sectors. Joe speaks regularly on international tax matters focusing particularly on transfer pricing and the Irish tax aspects of intangible property ownership and development. As well as being admitted to the Roll of Solicitors in Ireland, Joe has qualified as an attorney in New York, a chartered accountant and associate of the Irish Taxation Institute.
Carol A. Dunahoo, Partner, Baker McKenzie, Washington, DC
Carol Dunahoo is a member of Baker McKenzie’s Tax Practice Group. She has almost 30 years of international tax experience, including both high-level US government positions and client service. Ms. Dunahoo has been named a leading tax advisor in Chambers USA; World Tax, Guide to the World’s Leading Transfer Pricing Advisors; and The Best Lawyers in America. She is active in the International Fiscal Association, where she serves on the Executive Committee of the USA Branch and recently completed a term on the global Executive Committee. She also serves on the advisory boards for the annual OECD and IRS/GW tax conferences in Washington, DC.
Ms. Dunahoo’s practice focuses on international tax controversies, compliance, and policy, including transfer pricing, tax treaty, tax policy and other matters. She previously served as the US Competent Authority and Director, International (LMSB) at the US Internal Revenue Service, where she led US international tax administration efforts and was also responsible for the interpretation and application of US tax treaties, including advance pricing agreements, and other competent authority matters.
Ms. Dunahoo has represented the interests of the United States at meetings of the OECD’s Committee on Fiscal Affairs and of other multilateral organizations. She has experience representing clients before the IRS, the US Treasury Department and other tax administrators and policymakers throughout the world, as well as before the OECD, the UN, the US Congress and the European Commission.
Melinda E. Harvey, Attorney, Internal Revenue Service
Melinda Harvey is an attorney in Branch 2 of the Office of Associate Chief Counsel (International) where her areas of focus are the CFC and PFIC anti-deferral regimes. She is the principal drafter of the country-by-country reporting regulations. Before joining the IRS in 2013, Melinda was a manager in the International Tax Services - Financial Services tax group at PricewaterhouseCoopers LLP in Manhattan focusing on international tax issues of hedge and private equity funds. She received a J.D. and LL.M. (International and Comparative Law) from Duke University School of Law and an LL.M. in Taxation from Northwestern University School of Law.
The Honorable Orrin Hatch, Chairman, Senate Finance Committee
Orrin Grant Hatch was born on March 22, 1934, to Jesse and Helen Hatch. He married Elaine Hansen of Newton, Utah in 1957. Orrin and Elaine Hatch are the proud parents of six children, 23 grandchildren and 14 great-grandchildren. Now in his seventh term as Utah's senator, Orrin Hatch is the most senior Republican in the Senate. Among his many initiatives are the Balanced Budget Amendment to the Constitution, the Strengthening Our Commitment to Legal Immigration and America’s Security Act, the Religious Freedom Restoration Act, the Americans with Disabilities Act, the Antiterrorism and Effective Death Penalty Act, and the Utah School Trust Lands Exchange Act. Senator Hatch continues to lead in the fight to repeal Obamacare. He is on the front lines of legislative battles to secure the nation’s borders, stop the forced unionization of American workers, and to bring fiscal restraint back to Washington by ending the reckless spending that threatens to bankrupt the nation. Senator Hatch is the Chairman of the Senate Committee on Finance. He is also a member (and former Chairman) of the Judiciary Committee, a member (and former Chairman) of the Senate Health, Education, Labor, and Pensions Committee, and a member of the Joint Committee on Taxation. He also has the honor of serving on the Board of Directors for the Holocaust Memorial Museum in Washington, D.C.
John Hinman, Director, Field Operations, Transfer Pricing Practice, Internal Revenue Service
John Hinman is the Director, Field Operations in the Transfer Pricing Practice of the IRS Large Business and International (LB&I) Division. In this role, John oversees the field operations of the Transfer Pricing Practice economists, revenue agents, and tax law specialists who focus on complex transfer pricing issues of multinational business enterprises.
John is a graduate of the 2017 IRS Executive Development class. Prior to his current assignment, John served as Acting Director, Field Operations - Southeast (LB&I), Assistant to the Director, IRS Whistleblower Office, Assistant to the Director, Transfer Pricing Operations (LB&I), and as Assistant to the Director, Pre-Filing and Technical Guidance (LB&I). He has also held positions in LB&I as Executive Assistant (Technical) to the Deputy Commissioner International, and as an International Territory Manager. His international tax experience began as an IRS international examiner in 1987. John earned a Bachelor of Science Degree in Accounting from Wayne State University, and is a Certified Public Accountant and Charted Global Management Accountant.
Jud Judkins, Partner, Baker McKenzie, Washington, DC
Joseph "Jud" Judkins is a member of Baker McKenzie’s Tax Practice Group. He serves on the group’s Tax Controversy Steering Committee. Mr. Judkins clerked for the Honorable Herbert L. Chabot at the US Tax Court and also served as the Tax Court’s legislative counsel. Before the Tax Court, Mr. Judkins served in the US Navy Judge Advocate General’s Corps, where he focused on civil and criminal litigation. He continues to serve as a commander in the US Navy Reserve.
Tom Kane, Division Counsel, LB&I, Office of Chief Counsel, Internal Revenue Service
Tom Kane is currently the Division Counsel for the Office of Large Business & International Division Counsel function within the IRS Office of Chief Counsel in Washington, D.C. Within the IRS, the LB&I Division handles large business and international tax issues. As LB&I Division Counsel, Tom oversees the tax litigation conducted by the IRS in the U.S. Tax Court and legal advice provided to the IRS by over 300 LB&I attorneys and paralegals located throughout the country. Tom previously served as the Division Counsel with the Tax Exempt & Government Entities Division Counsel function. Tom received his J.D. degree (with distinction) from The John Marshall Law School, where he was a member of the law review staff, and has advanced degrees in taxation, international legal studies, and public health.
Judith Lemke, Vice President, Tax, Corning Incorporated
Jude Lemke was appointed Corning’s Vice President of Tax in September 2015. In this role, she lead’s Corning’s global tax function, with responsibility for worldwide tax planning, tax accounting, tax compliance and tax controversy. Her focus is on delivering bottom line tax planning results for Corning while at the same time maintaining the highest standards in all aspects of tax compliance and tax accounting.
Lemke brings over 35 years of diverse tax experience, including 3 years of public accounting with PriceWaterhouse, 13 years of private law practice with a top 200 national law firm, and 14+ years as the senior tax officer of four Fortune 500 companies: CareFusion, Alltel Communications, Pepsi Bottling Group, and Chiquita Brands International. Most recently she served as Senior Tax Counsel on the United States Senate Finance Committee as an advisor to Chairman Max Baucus. During her time with the Senate Finance Committee, Lemke made significant contributions to the corporate and international tax reform debate. She was the lead author of the “Cost Recovery and Tax Accounting Discussion Draft”, issued by the Senate Finance Committee on November 21, 2013 and co-author of the “International Tax Discussion Draft”, issued by the Senate Finance Committee on November 19, 2013.
Lemke earned a bachelor’s degree, a master’s degree and a J.D. from Case Western Reserve University in Cleveland, Ohio. She is a licensed attorney as well as a licensed CPA.
Carlos A. Linares-Garcia, Principal Economist, Baker McKenzie, Monterrey, Mexico
Dr. Carlos Alberto Linares Garcia is a principal economist of Baker McKenzie’s Latin America Transfer Pricing practice. He is knowledgeable in the fields of transfer pricing, financial valuation and antitrust. His professional experience includes more than 13 years in consulting and three years in the public sector. From 1993 to 1995, Dr. Linares was a deputy director with the International Tax Department of the Mexican Ministry of Finance in Mexico City. From 1996 to 1999, he was an associate economist at Houston-based Baker & Associates Energy Consultants, and from 2000 and 2004, he was a senior manager and a partner in the energy economics and transfer pricing group at a big-four firm in Houston and Monterrey. Dr. Linares received the Banamex Economics Award in 2000, as well as the Inter-American Social Security Award in 2002. He has lectured at various institutions such as the IFBD, Rice University, Universidad Autónoma de Nuevo León and the Tecnológico de Monterrey.
Dr. Linares is a partner and chief economist of the Latin America transfer pricing and economics practice of Baker McKenzie. He is responsible for coordinating compliance, planning and controversy transfer pricing projects for multinational companies with operations in Latin American countries, which have adopted transfer pricing regulations. He also coordinate projects in areas such as financial valuation, energy economics, antitrust and unfair foreign trade practices.
Henry John Louie, Deputy International Tax Counsel, Treaty Affairs, International Tax Policy, U.S. Department of Treasury
Henry Louie is the Deputy to the International Tax Counsel (Treaty Affairs) in the U.S. Treasury Department’s Office of Tax Policy. He joined the Treasury Department in 1996. His principal work areas encompass the negotiation of bilateral income tax treaties on behalf of the United States, the coordination of U.S. model tax treaty policies and representation of the United States at the Organization for Economic Cooperation and Development’s Working Party that examines issues related to the OECD Model Tax Convention. Mr. Louie currently serves as first Vice Chair of the United Nations Committee of Experts on International Cooperation in Tax Matters. Mr. Louie received his M.A. in Economics from Duke University in 1995 and his B.A. in 1990 from Georgetown University.
Samuel M. Maruca, Partner, Covington & Burlington LLP
Sam Maruca has practiced exclusively in the area of federal income tax since 1983, focusing in recent years on large-case controversies, including complex transfer pricing disputes. He has represented both U.S. and foreign-based multinational companies in the biopharmaceutical, information technology, internet commerce, communications and media, consulting services, heavy manufacturing, and retail sectors, in matters at the audit level, in IRS Appeals, in mediation, in competent authority, and in the courts.
His expertise includes the preparation of opinion letters and compliance advice relating to cross-border financing transactions and transfer pricing matters, interpretation of tax treaties, treatment of controlled foreign corporations under subpart F, taxation of inbound transactions, and the applicability of penalty regimes. In advising clients, he often collaborates with foreign legal advisers and works regularly with leading transfer pricing economists and industry experts.
From 2011-2014, Mr. Maruca served as the first Director of Transfer Pricing Operations in the Large Business & International Division of the Internal Revenue Service, where he had national responsibility for transfer pricing compliance and double tax cases under US tax treaties. Mr. Maruca also represented the IRS in connection with the Base Erosion and Profit Shifting (“BEPS”) initiative of the Organization for Economic Cooperation and Development (“OECD”).
Jeffrey Maydew, Partner, Baker McKenzie, Chicago
Jeffrey Maydew is the Chair of the Firm’s Global Tax Planning and Transactions Practice Group and a member of the Management Committee for the firm’s North American Tax Practice Group. He is ranked as a notable practitioner in Chambers USA – Illinois Tax (2016), and has been noted as a Recommended Lawyer in The Legal 500 US – International Tax (2015, 2016) and World Tax – Chicago (2013, 2015).
Mr. Maydew has more than twenty years of experience representing multinational organizations in tax-related matters. He is a frequent author and speaker on international tax topics before the Tax Executives Institute, American Bar Association, IUS Law Program and the International Fiscal Association. He is a co-author of a treatise on international taxation, US Corporations Doing Business Abroad. Mr. Maydew has taught courses in international taxation as an Adjunct Professor at Georgetown and the Northwestern University Law Center.
Mr. Maydew specializes in business taxation, particularly domestic and international tax planning for mergers, acquisitions and other major corporate transactions. His practice also includes private ruling requests as well as audit and tax controversy matters. He advises clients across a broad range of industries, including aerospace, automotive, consumer products, e-commerce, electronics and petrochemicals.
Donna McComber, Director of Economics, Baker McKenzie, Washington, DC
Donna McComber is a director of economics for Baker McKenzie Consulting LLC in Washington, DC. She is a seasoned transfer pricing advisor with deep technical insight into complex transfer pricing issues. Prior to rejoining Baker McKenzie, Ms. McComber was assistant director of the Advance Pricing and Mutual Agreement Program (APMA) under the US Internal Revenue Service's Large Business & International Division. She managed teams that were responsible for cases in the following countries: Argentina, Caribbean countries, China, Denmark, Eastern European countries, Germany, India, Ireland, Israel, Mexico, Portugal, Norway, Spain, Sweden, Switzerland, UK and Venezuela.
Prior to becoming assistant director, she was the deputy director (technical) and reviewed US positions and negotiated APA MAP cases with treaty partners including Australia, Canada, China, Denmark, Germany, Japan, Mexico, Korea, Switzerland, and the UK. Prior to the IRS, Ms. McComber was a senior economist with Baker McKenzie.
Jennifer Molnar, Partner, Baker McKenzie, Washington, DC
Jennifer Molnar is a partner in Baker McKenzie’s Washington, DC office. Her practice focuses on US federal income taxation of corporations, with an emphasis on international tax planning. Jennifer has more than sixteen years of transactional tax experience. She is a frequent speaker, including for TEI, IFA, and think and code tax conferences.
Jennifer's practice covers international tax planning and controversy matters for US and foreign-based multinational corporations. She advises on cross-border planning matters involving intellectual property, domestic and international acquisitions and reorganizations, post-acquisition restructuring, joint ventures, tax treaties, Subpart F planning, transfer pricing, global workforce and other matters.
Molly Moses, Managing Editor, think and code’s Transfer Pricing Report
Molly Moses became managing editor of think and code’s Transfer Pricing Report in 2010 after working on the publication as a reporter for 18 years. Career highlights include coverage of DHL’s tax court trial in 1997, interviews with current and former government officials, and enterprise reporting on the U.S.-Canada relationship. Before coming to think and code in 1993, she worked in the reporter’s office of the U.S. Tax Court. Molly received a B.A. in English from Carleton College in 1989.
The Honorable Richard Neal (D), Ranking Member, House Committee on Ways and Means
Congressman Richard E. Neal represents the First Congressional District of Massachusetts in the United States Congress. Richard Neal was born in Worcester, Massachusetts on February 14, 1949 and was raised and educated in the City of Springfield. He is a 1972 graduate of American International College, where he received his Bachelor's Degree in Political Science and was a member of the National Honor Society. He received his Masters Degree in Public Administration from the Barney School of Business and Public Administration at the University of Hartford in 1976.
Richard Neal was first elected to the United States House of Representatives in 1988. He is the Ranking Member of the tax-writing Ways and Means Committee.
Congressman Neal is the dean of both the Massachusetts Delegation and the New England Congressional Delegation. He is a long-time guest lecturer at the University of Massachusetts in Amherst, and a Trustee at Mount Holyoke College. He is a National Trustee of John F. Kennedy Library in Boston. He served as the Mayor of the City of Springfield from 1984 to 1988, and was highlighted in Newsweek Magazine for his many accomplishments during that time.
Congressman Neal has been a lead sponsor of legislation to prevent American companies from moving offshore to avoid paying U.S. taxes. He has sponsored legislation that would increase the national savings rate by encouraging the use of individual retirement accounts, and has worked to make health care and tuition expenses tax deductible for middle class people. He successfully led the charge to eliminate the Alternative Minimum Tax (AMT) for middle-class families in America. He has a long legislative history of fighting to preserve and protect Medicare and Social Security.
Congressman Neal is an At-Large Whip for the House Democrats. He is a co-chairman of the New England Congressional Caucus, where he advocates for the unique regional interests of the six New England States. Congressman Neal is the Democratic Leader of the Friends of Ireland Caucus.
Mark A. Oates, Partner, Baker McKenzie, Chicago
Mark A. Oates is listed in Euromoney’s Guide to the World’s Leading Transfer Pricing Advisers. He has litigated many high profile cases won by taxpayers in the last decade, and has actively consulted on other prominent cases. He has also handled various international tax litigation cases involving issues in tax treaty interpretation, Subpart F and foreign tax credit — and a host of domestic issues in mergers and acquisitions, leveraged buy-out, valuations, research credit, inventory and civil fraud. Mr. Oates is the immediate past chair of the Firm’s North America Tax Litigation Practice, and has an active pro bono criminal practice.
Since 1985, Mr. Oates has concentrated on large case tax litigation. He also devotes a significant portion of his career to criminal defense, including defending corporations and individuals in tax fraud, money laundering, State and Commerce Department export issues and Classified Information Procedures Act cases. Mr. Oates has written numerous articles, and has served as a regular columnist and on the Advisory Boards of the Journal of Global Transactions and the Journal of Global Transfer Pricing.
Joshua D. Odintz, Partner, Baker McKenzie, Washington, DC
Joshua Odintz is a partner in Baker McKenzie’s North America Tax Practice Group. Mr. Odintz has over 14 years of tax experience, having served in high-level government positions in the US Department of the Treasury and the Senate Finance Committee. He was previously a senior adviser for tax reform to the Assistant Secretary of the Treasury as well as acting tax legislative counsel, and chief tax counsel to the President’s National Commission on Fiscal Responsibility and Reform, where he was instrumental in formulating the tax proposals contained in the report titled the Moment of Truth. He is a frequent speaker at ABA Tax Section, NY State Bar Tax Section, Practising Law Institute and Federal Bar Association tax meetings and conferences. Mr. Odintz was recognized in Washingtonian Magazine among Washington, DC Top Lawyers (Tax Law) in 2015.
Deborah Palacheck, Director, Treaty Administration, LB&I, Internal Revenue Service
Deborah Palacheck currently serves as the Director, Treaty Administration, in the Large Business & International Division of the Internal Revenue Service. In this role, Deborah is responsible for the administration of aspects of U.S. tax treaties and related competent authority programs, including exchange of information and non-allocation treaty interpretation issues. Prior to her current role, Deborah worked as Assistant to the Deputy Commissioner, International, LB&I. Other IRS positions included Deputy Director, Pre-Filing and Technical Guidance, and Senior Advisor to the LB&I Division Commissioner. Before joining the IRS, Deborah worked on tax controversy matters at a law firm in Washington, DC. Deborah received an LLM in Taxation from New York University, a J.D. from Yale Law School, and a B.S. and B.A. from the University of Florida.
Holly Paz, Director, Pass Through Entities Practice Area, Internal Revenue Service
Holly Paz is the Director of the Pass Through Entities Practice Area (PTE PA) in the Large Business and International (LB&I) Division of Internal Revenue Service (IRS). LB&I Pass Through Entities (PTE) contains S Corporation and Partnership Specialty teams that provide service to all of LB&I. The Partnership Specialty teams provide assistance concerning partnership taxation and the TEFRA & Electing Large Partnership (ELP) procedures. The S-Corporation Specialty team addresses issues on S corporation returns, Form 1120S, and their owners as well as cooperative returns, Form 1120-C. PTE also has responsibility over compliance matters related to tax shelter promoters. Holly previously served as the Director, Corporate Issues and Credits, in the Large Business & International Division’s Enterprise Activities Practice Area. She also served as Deputy Director (Content Development), LB&I. Other IRS positions included Director of EO Rulings & Agreements, TE/GE and attorney-advisor, Taxpayer Advocate Service. Holly also spent eight years as a tax attorney in private practice before joining the IRS. Holly has a law degree from the University of Pennsylvania Law School.
Melinda R. Phelan, Partner, Baker McKenzie, Dallas
Melinda R. Phelan is a partner in Baker & McKenzie’s Dallas office, and member of the North America Tax Practice Group Management Committee. She is also the chair of the Firm’s North America Transfer Pricing sub-practice group and a member of the Global Transfer Pricing Steering Committee. Ms. Phelan regularly advises on international tax planning, transfer pricing, post-acquisition restructuring, and domestic and international acquisitions and reorganizations, and has been involved in numerous restructuring, global transfer pricing projects and advance pricing agreements. She spends a significant amount of time dealing with the design and implementation of numerous structures to minimize global taxation, and has also been involved in numerous domestic and international mergers, acquisitions and reorganizations. Ms. Phelan’s practice includes dispute resolution, and she has represented various multinational clients at the audit and appeals levels.
Salim R. Rahim, Partner, Baker McKenzie, Washington, DC
Salim Rahim has extensive experience in transfer pricing matters, including transfer pricing planning, compliance, and tax controversy. He has represented clients in all administrative phases of a controversy. He has also represented companies in various alternative dispute resolution forums, particularly the Advance Pricing & Mutual Agreement Program. Mr. Rahim is the Chair of the Firm’s North America Transfer Pricing Sub-practice Group.
Mr. Rahim is a frequent speaker on transfer pricing matters in seminars sponsored by various organizations and universities. Mr. Rahim has given speeches on transfer pricing matters, participating in programs sponsored by think and code, Alliance for Tax, Legal and Accounting Seminars, Tax Executives Institute, International Tax Review and the American Bar Association.
The Honorable Tom Reed (R), Member, House Committee on Ways and Means
Tom Reed was first elected to the House of Representatives in a special election in November 2010. Since then, he has stood with the people of the Southern Tier, Finger Lakes Region, and Western New York. By focusing on job creation and helping those in our communities including students, senior citizens, and veterans, Team Reed strives to make New York a better place in which to live and work.
Tom currently represents New York’s 23rd District. He serves as a member of the Ways and Means Committee, which is responsible for addressing issues of tax policy, trade, health care, and Social Security. He sits on the Trade, Health, and Human Resources subcommittees. He serves as Co-Chair of the Congressional Diabetes Caucus, the House Manufacturing Caucus, and the Problem Solvers Caucus.
The mission that drives Tom is to continue to be accessible and help anyone in need. Tom and his team have completed more than 10,000 constituent cases, resolving issues with the Internal Revenue Service (IRS), Veterans Administration (VA), Social Security Administration (SSA) and other federal agencies.
A caring and accessible leader, Tom values the thoughts and concerns of the people from across the district, which is why he has held more than 200 public town hall meetings since taking office.
Tom remains committed to championing job creation by tackling our national debt, reducing burdensome regulations on small businesses, developing an “all of the above” energy policy, and reforming our tax code.
He is the youngest of 12 children raised by Tom Sr. and Betty Barr Reed. Tom’s father was a career Army officer, who worked his way through the enlisted ranks, and was a decorated veteran of both World War II and the Korean War. Tom married his wife, Jean, in 1996. Tom, Jean, and their two children, Autumn and Will, currently live in Corning, in the house built by Tom’s grandfather in the early 1920s.
Tom graduated from Alfred University in 1993 and from Ohio Northern University College of Law in 1996. His legal career began shortly thereafter in Rochester. In 1999, he returned to his hometown of Corning. After opening a private legal practice, Tom also began a business in real estate. He successfully ran for mayor and served as Mayor of Corning from 2008-2009. Tom helped change the political climate in Corning, and is now working to do the same in Washington.
Daniel A. Rosen, Partner, Baker McKenzie, New York
Daniel Rosen is a partner in the North America Tax Practice Group in New York. He is a seasoned tax lawyer with over 16 years of experience with the Internal Revenue Service. Mr. Rosen was a key participant in the drafting of published guidance and administrative directives involving judicial doctrines for the IRS Large Business and International Division (LB&I). He served as IRS counsel in many cases that resulted in published opinions and is a frequent speaker for George Washington University School of Law, the Practising Law Institute, Tax Executives Institute and the ABA. Additionally, Mr. Rosen served during law school as business editor of the Hofstra Law Review. He is an adjunct professor of law at New York Law School.
Mr. Rosen's practice focuses upon large case tax litigation and administrative tax controversies. He has been responsible for litigating some of the largest, most complex, and most sensitive cases pending before the United States Tax Court. He has litigated precedent-setting cases involving a wide variety of international and domestic tax issues, including transfer pricing, hybrid instruments, corporate and individual tax shelters, and research and development tax credits. He has worked closely with the US Department of Justice, Tax Division, on related cases and cross assignments, and has advised LB&I executives, managers and examiners on tax controversy matters, including settlement initiatives.
Mr. Rosen has broad experience representing clients under investigation by the US Congress, including the Permanent Subcommittee on Investigations. He assists clients during all phases of investigation, including responding to information and document requests, witness interviews, and hearings.
Bill Sample, Corporate Vice President, Worldwide Tax, Microsoft Corporation
Bill is responsible for all corporate tax matters at Microsoft and is a member of the Finance Leadership Team which governs the operation of the corporate finance function at Microsoft. Since first entering the software industry in 1989, Bill has been involved with regulatory and legislative efforts particular to the software industry, including subpart F manufacturing status, revenue characterization & withholding, FSC/ETI/Domestic Production benefits for software revenue, international taxation of e-commerce including participation in the OECD Business Profits TAG, and the computer software carve-out from the Section 197 intangibles amortization rules. Bill chaired the R&D Credit Coalition, representing a diverse group of trade associations and companies pursuing a permanent and enhanced R&D tax credit, for 17 years. He is Chair of the USCIB Taxation Committee and a Vice Chair of BIAC, participating in the business consultation on the OECD’s BEPS project.
Prior to entering the software industry, Bill was a senior tax manager at one of the Big 8 accounting firms. He has an AB in economics from Harvard College, a Masters of Science in Taxation from Bentley College, and is a licensed CPA.
Bill is a member of The Overlake School Board of Trustees. He serves as Chair of the Board of the Greater Northwest Chapter of the National Multiple Sclerosis Society.
Moiz Shirazi, Principal Economist, Baker McKenzie, Chicago
Moiz Shirazi is a Principal Economist in the Chicago office. He focuses on transfer pricing and provides his clients with economic analyses and valuations that assist them in planning and supporting business reorganizations, as well as establishing and documenting global transfer prices. Mr. Shirazi has led economic analyses for a diverse set of clients from many different industries, including analyses on transfer pricing planning in the context of global restructuring, assistance in negotiating advance pricing agreements (APAs) with the IRS, intangible property valuation, preparing US and foreign transfer pricing documentation and transfer pricing controversy.
Mr. Shirazi focuses his practice on transfer pricing and valuation matters in relation to pricing of intercompany loans, cash pooling arrangements, guarantee fees, thin capitalization, stock option valuation, credit swaps, interest rate swaps, currency swaps, and other financial instruments. He has worked with some of the largest companies in the financial services industry to establish pricing for financial instruments, shared services arrangements, global trading and investment management operations, and revenue sharing in the context of client acquisition. Mr. Shirazi has also worked with some of the largest insurance companies in pricing for reinsurance transactions and remuneration for underwriting services.
Richard L. Slowinski, Partner, Baker McKenzie, Washington, DC
Richard Slowinski chairs the Firm’s Washington Office Tax Practice, serves on the Firm’s North American Transfer Pricing Steering Committee and is the hiring partner for the Washington Office. His practice focuses on US federal income taxation of corporations, with an emphasis on international tax planning and controversies involving international tax issues. He is ranked as a leading individual in taxation by International Tax Review’s World Tax Survey and worked in the Tokyo office of Baker McKenzie. Mr. Slowinski is a frequent presenter at seminars sponsored by the Tax Executives Institute, the Japan Tax Association, the Federal Bar Association and other professional organizations.
Mr. Slowinski advises clients on corporate taxation, including cross-border tax controversy and planning matters involving transfer pricing of tangible products, intellectual property and services, global restructurings, effective tax rate minimization, tax treaties, cross-border tax planning, regulatory lobbying and other matters. His client base includes US and foreign companies in a wide range of industries, including electrical equipment and electronics, automobiles, recreational vehicles, hospitality, financial services, e-commerce, aerospace equipment, pharmaceuticals, industrial products, diversified products, consumer products and telecommunications products and services.
Robert Stack, Former Deputy Assistant Secretary, U.S. Department of Treasury
Bob Stack is the Former Deputy Assistant Secretary for International Tax Affairs in the Office of Tax Policy at the U.S. Department of the Treasury. In this capacity, he was responsible, on behalf of the Assistant Secretary, for the conduct of legal and economic aspects of tax policy relative to the representation of the United States in bilateral and multilateral relations with other countries, as well as advising the legal and economic staffs within the Office of Tax Policy, other offices of the Treasury Department and other government agencies as to policy analysis and interpretation for domestic legislation and administrative guidance in all matters involving cross border taxation.
Anna Theeuwes, President, TEI EMEA
Anna Theeuwes is currently President of Tax Executives Institute (TEI)’s EMEA Chapter and has served in the past as Chair of TEI’s European Direct Tax Committee, responsible for engaging with the EU, the OECD and other international organisations. She has
over 20 years of experience in advising on international tax matters, first with PriceWaterhouseCoopers in Brussels, Belgium and subsequently within the Royal Dutch Shell group out of The Hague, Netherlands. At present, she is Global Tax Policy Manager at Shell International BV.
She is a frequent contributor to UN and OECD tax debates on international tax and has participated in business organisation discussions towards the European Commission. She represents TEI at the EU Platform for Tax Good Governance. She studied law at Leuven University (KUL), Universite de Poitiers and Heidelberg’s Karl-Ruprecht University and tax law at Erasmus University in Rotterdam.
Angela J. Walitt, Partner, Baker McKenzie, Washington, DC
Angela Walitt is a partner in Baker McKenzie's North America Tax Practice Group. She advises clients on a variety of corporate and international taxation matters, particularly on transfer pricing matters. Angela speaks frequently on transfer pricing, international tax, and insurance tax issues, participating in programs sponsored by the American Bar Association, the Federal Bar Association, think and code and Tax Executives Institute, among others.
Angela's practice focuses on US federal income taxation of corporations, with an emphasis on international tax planning, transfer pricing and controversies involving international tax issues. She practices primarily in the areas of transfer pricing and tax planning and works with US-based and foreign-based multinationals in a wide range of industries, including manufacturing, retail, IT, insurance and financial services. She assists clients with compliance with US and foreign transfer pricing laws and related cross-border tax issues, including assistance with Treaty-based resolutions of disputes and tax audits. Angela is also seasoned in issues relevant to the insurance industry and related party/captive insurance arrangements and with FATCA compliance.
Nicole Welch, Treaties and EOI IPN Manager, Treaty Assistance and Interpretation Team, Internal Revenue Service
Nicole Welch is a manager in the Treaty Assistance and Interpretation Team (TAIT) within the office of the U.S. Competent Authority. During her time in TAIT, Ms. Welch has supported MAP negotiations in non-allocation cases, the activities of the Treaty and Exchange of Information practice networks, and the IRS’s engagement in OECD and Forum on Tax Administration initiatives. Before joining TAIT, Ms. Welch practiced law at Covington & Burling LLP, where she represented clients in federal tax planning and controversy matters, especially those concerning the inbound and outbound international taxation of multinationals.
Nancy Wiltshire, Acting Director, Advance Pricing and Mutual Agreement Program, Internal Revenue Service
Nancy Wiltshire has served as the Assistant Director, APMA since February 2016. Prior to her Assistant Director role Nancy served as the EOI Program Manager, responsible for coordinating Exchange of Information (EOI), supporting FATCA developments impacting EOI, coordinating with Criminal Investigation and Department of Justice to make and respond to requests for information related to Tax Treaties. She led efforts with the Global Forum Peer Review Group, and provided expert advice with respect to the IRS’ responsibilities and rights flowing from Exchange of Information provisions in bi-lateral/multi-lateral agreements. Prior to that, Nancy was an Analyst in Tax Treaty (now APMA) where she was responsible for negotiating complex Transfer Pricing and Treaty Interpretation issues with European Partners. Nancy began her IRS career as a Revenue Agent in 1991. Nancy graduated from Sweet Briar College with a degree in Economics.
Christopher J. Wolter, Vice President, Tax, Boeing Company
Christopher Wolter is vice president of Tax for The Boeing Company, the world's largest aerospace company and leading manufacturer of commercial jetliners and defense, space and security systems. Named to this position in 2015, Wolter leads the team that executes Boeing’s global tax strategy and plans.
Previously, Wolter served as director of Tax, overseeing all aspects of United States federal and state taxes, including legislative matters, planning, controversy, compliance and financial reporting.
Prior to joining Boeing in 2002, Wolter held the position of senior manager of Tax Consulting at Ernst & Young LLP. During his time at E&Y, Wolter worked with large corporate clients including consumer products and industrial products companies, private equity firms and entrepreneurial companies. Wolter worked in the company’s offices in Michigan & Illinois and participated in a rotation with the National Tax department.
Wolter attended Grand Valley State University in Allendale, Michigan. He obtained a bachelor of Business Administration, majoring in Accounting and is a certified public accountant. Wolter’s memberships include the Tax Executive Institute Inc. (TEI), National Foreign Trade Council (NFTC) and The Illinois Federation of Taxpayers.
Shanwu Yuan, International Tax Director, Baker & McKenzie Consulting LLC, New York
Shanwu Yuan assists large multinational enterprises with operations in China and elsewhere on various transfer pricing issues, in particular advance pricing arrangements (APAs) and mutual agreement procedures (MAPs). He also works on other Chinese tax issues, including interfacing with the Chinese tax authorities on behalf of taxpayers.
Cynthia Zuk, Director of Global Transfer Pricing, Willis Towers Watson
Cynthia Zuk is the Director of Global Transfer Pricing for Willis Towers Watson. Cynthia is responsible for the development and implementation of the firm’s transfer pricing policies and strategies. She manages the global transfer pricing documentation process, required disclosures and works with key stakeholders in the firm to ensure transfer pricing best practices are being utilized. In addition, she manages transfer pricing controversy and oversees due diligence in M&A transactions as related to transfer pricing matters.
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